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POLICY

Interaction with Government Officials

Personal Capacity vs. NYU Representative

 

Obligation to Identify Personal Capacity and Refrain from Using NYU Resources
 

NYU does not discourage members of the University Community from engaging in Political Campaign Activity or Lobbying Activity on their own time in a personal capacity, or on behalf of groups or organizations to which they belong.

However, when activities are undertaken in a personal capacity, it is the responsibility of the University Community member involved to state expressly that the activity is conducted in a personal capacity and not in his or her capacity as a representative of NYU.

Subject to limited exceptions for permissible certain student activities, NYU resources of any kind (e.g., NYU letterhead, email, secretarial support, printers, office supplies, meeting rooms) may never be used in connection with any Political Campaign Activity; and NYU resources may be used in connection with Lobbying Activity undertaken in a personal capacity only when approved by the NYU Office of Government and Community Affairs or the NYU Langone Medical Center Office of Government Affairs, as appropriate (collectively, “OGA”).

 

Activities Undertaken as NYU Representative

 
Prohibited Activity: Gifts to Government Officials and Political Campaign Activities
 

In their capacity as representatives of NYU, members of the University Community are strictly prohibited from:

  • Endorsing or opposing candidates for public office (e.g., presidential, congressional, state, city);
  • Contributing institutional funds to political campaigns, parties, or PACs;
  • Using institutional resources (including space in an NYU building) to host or conduct a partisan political event;
  • Hosting or conducting partisan political events (including political fundraising); and
  • Publishing materials that support a particular candidacy or party.

There are limited exceptions to these rules for certain activities conducted as part of NYU’s educational mission (e.g., student editorials on political matters appearing in student newspapers, or events hosted by student groups). Any questions concerning the scope of the prohibited activity in this policy should be referred to OGA. Contact individuals are provided in the section of this policy entitled “Procedures for Implementation.”

Where a candidate for public office will be coming to NYU for a non-partisan purpose, the OGA must be contacted, as it will send the candidate a letter prior to the candidate’s appearance confirming the purpose of the visit and reminding the candidate that, because NYU is a 501(c)(3) educational organization, he or she cannot engage in any political activities while on the NYU campus.

Activity Requiring Advance Approval: Contacts with Government Officials

Members of the University Community must contact the OGA prior to any interactions with Government Officials if they:

  • Would like to invite a Government Official or a candidate, or are approached by a Government Official or candidate about visiting campus;
  • Would like to make a gift to a Government Official, including the purchase of a meal;
  • Are contacted by a Government Official requesting the use of space on campus;
  • Are considering contacting a Government Official with respect to legislation or executive actions or decisions government policies, programs or regulations; or with respect to government funding, including contracts and grants (note faculty exceptions below).

The OGA will review the proposed interaction, which may be reportable on city, state, or federal levels, and will provide guidance on the interaction.

Permitted Activity: Policy Expertise/Testimony and Contacts With Grant-Making Agencies

Faculty are encouraged to:

  • Accept invitations from the government to provide policy expertise and testimony in their field of expertise to Government Officials and staff; and
  • Contact program and grant/program officers to discuss prospective or ongoing governmental funding projects that have been, or will be, awarded through a competitive review process. (Note that faculty should review the applicable grant request for proposal for any restrictions it may contain on who can be contacted.)

Faculty and researchers who are members of the University Community do not need to contact the OGA prior to engaging in such interactions.

 

Procedures for Implementation

 

Members of the University Community should seek guidance on how these rules apply to a particular situation by contacting the NYU Office of Government and Community Affairs or the NYU Langone Medical Center Office of Government Affairs, as appropriate:

  • For all schools, except the School of Medicine and NYU Hospital, individuals should contact the Vice President for Government Affairs & Community Engagement (212-998-6859).
  • For the School of Medicine and NYU Hospital, individuals should contact the Vice President, Government Affairs (212-404-4077).

The OGA will seek advice from the Office of General Counsel where questions of law arise.

 

Related Policies

 

None

About This Policy

Effective Date: September 10, 2012
Issuing Authority: Office of Government and Community Affairs and Office of General Counsel
Responsible Officer: General Counsel
Office Name: Office of General Counsel
Button: display or hide Purpose of the Policy

The purpose of this policy is to ensure compliance with Federal, State, and City laws that regulate Political Campaign Activity and Lobbying Activity and to ensure that NYU’s Office of Government and Community Affairs is informed of such activities so that it may offer guidance and assistance.

Under applicable law, NYU is prohibited from engaging in Political Campaign Activity and may only engage in an insubstantial amount of Lobbying Activity (defined in the Internal Revenue Code and applicable regulations), as part of NYU’s overall activities.  In addition, NYU and certain members of the University Community are subject to various registration and reporting requirements concerning activities that constitute Lobbying Activity under Federal, State, and City law (each has different requirements, reporting thresholds, and definitions). 

Button: display or hide Who needs to know this policy

This policy applies to any member of the University Community who (a) is acting on behalf of NYU or (b) utilizing NYU resources in connection with Political Campaign Activity or Lobbying Activity.  Activities that may be undertaken by members of the University Community in a personal capacity are not limited, but members of the University Community must clearly distinguish between their personal capacity and their capacity as a representative of NYU and, with limited exceptions for certain permissible student activities, may not use NYU resources in connection with their personal Political Campaign Activity or, without approval, in their personal Lobbying Activity. 

Button: display or hide Policy Definitions

“Candidate for Public Office” means an individual who offers himself or herself, or is proposed by others, as a contestant for a national, State, or local elective public office.  The term includes not only candidates who are elected by individual voters, but also candidates who must be confirmed by a vote of a legislative body such as a senate or city council.

“Government Official” means an elected or appointed official in a branch of government (including those serving in executive branch agencies, departments, and divisions), as well as the staff of such officials.

“Lobbying Activity” for purpose of this policy means any attempt to influence legislation, policy actions, or government decisions, or to seek funding or contracts or other government support. Grassroots lobbying, which includes organizing the general public to take action on legislative matters, is also considered Lobbying Activity.  The legal definition of lobbying varies by applicable law.

“NYU” includes the schools, colleges, institutes, and other administrative units of NYU, NYU’s Global Network University sites, and all University Affiliates, as each term is defined in NYU’s Policy on Policies.

“Political Campaign Activity” means directly or indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to) any Candidate for Public Office.

“University Community” means NYU faculty, including visiting faculty; researchers, including persons participating in research at or under the auspices of NYU; employees; professional staff, including medical, dental and nursing staff; volunteers; fellows, trainees and post-doctoral appointees; students; and consultants, vendors and contractors.

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